1993 Conn. Super. Ct. 10828 | Conn. Super. Ct. | 1993
The defendant Midland has moved to strike the Third and Fourth Counts of the complaint on the grounds that: (1) the defendant Midland is a product seller within the meaning of Product Liability Act which provides the exclusive remedy to the plaintiff and which does not permit recovery of the commercial losses claimed; and (2) the plaintiff may not assert a claim under the UCC because the provisions of the code do not apply to the plaintiff and the plaintiff has no contractual relationship with the defendant Midland.
Our Product Liability Act in General Statutes
Following the Verdon decision, the legislature amended the Product Liability Act so as to specify, in
The Product Liability Act is the exclusive remedy for those claims encompassed by its provisions. Winslow v. Lewis Shepard Inc.,
With respect to the claims made in the Third Count under the UCC, the defendant asserts that the UCC, by its terms, does not apply to the plaintiff inasmuch as there is no contractual relationship between the plaintiff and the defendant and, therefore, the necessary requirement of privity does not exist. The plaintiff asserts that, if no remedy exists under the Product Liability Act and if no remedy exists under the Uniform Commercial CT Page 10831 Code, then the plaintiff will have no remedy at all. Under such circumstances the plaintiff asserts that he may proceed under the UCC, despite the lack of privity, because of the absence of any other available remedy. See Utica Mutual Ins. Co. v. Denwat Corp.,
As a matter of public policy, the courts have dispensed with the requirement of privity with respect to tort actions, at least involving claims for personal injury, death and property damage, so that the requirement of privity is only applicable to actions growing out of a contract theory of recovery. Coburn v. Lenox Homes, Inc,
Under the product Liability Act, claims may be made notwithstanding the fact that the claimant did not buy the product from or enter into any contractual relation with the product seller. General Statutes
"A seller's warranty whether express or implied extends to any natural person who is in the family or household of his buyer or who is a guest in his home if it is reasonable to expect that such person may use, consume or be effected by the goods and who is injured in person by breach of warranty. This section is neutral with respect. to case law or statutory law extending warranties for personal injuries to other persons. A seller may not exclude or limit the operation of this section."
The plaintiff is clearly not within the provisions of the above quoted stated and he cannot be considered a third party beneficiary of any express or implied warranty made by the defendant.
The legislative history of the 1984 amendments make it clear that commercial losses between commercial parties are not covered by the product Liability Act. However, the legislative history does not appear to provide any insight as to whether the legislature is attempting to deal with the situation presented, that is whether CT Page 10832 non-contracting commercial parties may avail themselves of the provisions of the UCC to recover their commercial losses. The legislative history does reveal, however, that a comment, albeit by a non-legislator, indicates that there is a universal practice of commercial enterprises to contain comprehensive insurance which typically includes business interruption losses. Accordingly, the Court can find no indication that the legislature intended to dispense with the requirement of privity when the Legislative referred commercial losses between the commercial parties to the UCC for resolution, which, by its terms, does not apply to the plaintiff.
On one hand, the plaintiff claims that it has sustained commercial losses through no fault of its own as a result of a manufacture of a defective product by the defendant. The plaintiff therefore claims that it should have a remedy for those claims. Conversely, "(p)ermitting recovery for all foreseeable claims for purely economic loss could make a manufacturer liable for vast sums. It would be difficult for a manufacturer to take into account the expectations of persons downstream who may encounter its product. . . `The law does not spread its protection so far.'" (citation omitted). East River Steamship Corp. v. Delaval Inc.,
The issue of whether the plaintiff should have a remedy or whether such a remedy would be an undue burden upon a manufacturer presents a question of public policy which has been decided by the legislature. The legislature has seen to fit to carve out commercial losses between commercial parties for treatment "only" under the UCC which does not by its terms provide a remedy to the plaintiff. Connecticut General Life Ins. Co. v. Grodsky Service Inc.,
Cohen, Micci Thomas for plaintiff.
J. E. Lee for defendant. CT Page 10833